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                   CONCURRING STATEMENT OF 

     Re:  WQAM License Limited Partnership, Licensee of 
Station WQAM(AM), Miami, FL, Notice of Apparent Liability 
for Forfeiture

     I concur in the decision to find these broadcasts 
indecent in violation of the statute.  I note that the 
broadcaster in this instance claims that it has neither a 
tape nor a transcript and that, without such a record, the 
Commission cannot determine if the material violates the 
statute.  Many broadcasters have argued that the 
Commission's proposal to require broadcasters to keep a tape 
or transcript of what they air is unnecessary, yet this 
broadcaster claims that such a record is necessary for a 
finding of indecency.  In this instance, the complainant was 
able to provide a significant excerpt and I believe a case 
could be made that there were separate indecent utterances 
within these broadcasts.